Evaluation of Health Canada's Food and Nutrition Program – 2018-2019 to 2023-2024

Final report – March 2025

Prepared by the Office of Audit and Evaluation
Health Canada

On this page

• Executive summary
  • Background and evaluation scope
  • Findings
  • Recommendations
• Management Response and Action Plan
  • Recommendation 1
  • Recommendation 2
  • Recommendation 3
  • Recommendation 4

Executive summary

Background and evaluation scope

The Food and Nutrition Program is the federal health authority responsible for establishing regulations, guidelines, standards, and policies on food safety, nutrition and healthy eating. The Program also conducts reviews and assessments of the safety of food ingredients, veterinary drugs for food-producing animals, food processes, and consumer food products. It encompasses activities that help ensure the safety of Canada's food supply and provide information to Canadians to help them make safe, informed and healthy eating choices. The Food and Drugs Act and the Food and Drug Regulations, administered by Health Canada and CFIA, in addition to CFIA's Safe Food for Canadians Act and Safe Food for Canadians Regulations, provide the legislative and regulatory frameworks for the Canadian food safety and nutrition system. Over the course of the evaluation period, the Program spent approximately $439 million.

The Program is managed through the Health Products and Food Branch (HPFB), with direct support from the Regulatory Operations and Enforcement Branch (ROEB) and the Communications and Public Affairs Branch (CPAB). Certain aspects of the Program operate in partnership with the Canadian Food Inspection Agency (CFIA), the Public Health Agency of Canada (PHAC), and Agriculture and Agri-Food Canada (AAFC).

Building on the results of the previous evaluation from 2018-19, this evaluation examined the contextual influences on the Program, the achievement of expected outcomes, as well as the efficiency and economy of activities between 2018-19 and 2023-24. The evaluation used multiple lines of evidence, including document reviews, interviews, and analyses of financial and performance measurement data.

Findings

World-class food safety system

Canada maintains a world-class food safety system, ranking first for food quality and safety out of 113 countries in the 2022 Global Food Security Index. The rates of food-borne illnesses in Canada are generally in line with or lower than those in the United States and the European Union (EU). Public confidence in Canada's food safety system is high, with eight in ten respondents in a 2019-20 survey expressing confidence in the safety of food products sold in Canada.

The Program's labs and expertise are recognized internationally, with investments in state-of-the-art genomics laboratories enhancing Canada's credibility in international food science discussions. The Program has also contributed to the advancement of food safety and nutrition science through the publication of numerous articles in peer-reviewed journals.

Contextual influences and program responses

The Food and Nutrition Program has effectively responded to various scientific, industry, and consumer influences through innovative approaches, flexibility, and collaboration with partners and stakeholders. The COVID-19 pandemic and supply chain disruptions were significant events during the evaluation period. The Program addressed these challenges through coordinated efforts and policies to handle food supply interruptions, and by using communication strategies that emphasized safe food handling and storage practices to minimize wastage and increase food preservation.

Health Canada emphasized the importance of safe food handling and storage when rising food prices led to changes in food consumption patterns, such as consuming food past its best before date. Additionally, the Program demonstrated flexibility by rearranging its implementation schedule for nutrition labelling requirements due to pandemic-related challenges.

Engagement of Canadians, partners, and stakeholders

The Program has strived to ensure that Canadians, partners, and stakeholders are informed of policies, priorities, and Program delivery through consultations, meetings, and email communications. Health Canada leads federal-level communications on food safety and nutrition, with outreach and engagement efforts coordinated by the Health Products and Food Branch (HPFB) and the Communications and Public Affairs Branch (CPAB). Health Canada's communication strategy shifted in 2019 to focus more on children, youth, and at-risk populations, using digital and social media platforms to disseminate food safety and nutrition messages. However, some external interviewees mentioned challenges such as outdated Program information and complex navigation of online resources.

Only 48% of partners and stakeholders felt they had engaged effectively with the Program, falling short of the target of 60%. External interviewees expressed a desire for longer consultation timelines, earlier engagement, greater transparency, and increased engagement opportunities.

Responding to food safety and nutrition issues

Health Canada has crafted both regulatory and non-regulatory measures to tackle current and emerging high-risk food safety and nutrition challenges. The Program was successful in its response to an infant formula shortage in 2022 having taken swift action by issuing a public advisory and developing an interim policy to allow the importation of eligible products, which fostered supply stability. Similarly, during the COVID-19 pandemic, the Program developed new guidance and web content to address emerging food safety concerns. Health Risk Assessments (HRAs) conducted by the Food and Nutrition Directorate adhere to established service standards, and processes have improved since 2018. Additionally, the rate of pre-market assessments being completed within service standards has also surpassed the Program's target.

However, stakeholders stressed the importance of regular regulatory updates and increased outreach to ensure industry compliance with evolving standards. Feedback highlighted issues such as unclear roles and overlapping responsibilities when implementing new regulations, which points to a need for better engagement with CFIA. Earlier and more extensive engagement with CFIA during the development of new policies and regulations would provide opportunities to highlight and address challenges, such as resource implications and clarity on roles and responsibilities.

Efficiency and economy

The Program has effectively managed financial challenges, including budget variances and staff reductions, by implementing a Business Process Improvement strategy, for example. Despite annual fluctuations in the variance between budgeted and actual spending, the Program stayed within its budget with spending ranging from 77.4% to 98.7% of the planned budget during the evaluation period. The Food Directorate, for example, closely aligned its spending with the budget at 98.4%. However, challenges remain such as future funding uncertainty, limited resources for research, travel, and surveillance, and the need for more relevant and clear performance measurement data for decision making.

The Program's continuous improvement efforts, including Lean and Six Sigma training for employees, aim to enhance efficiency and cost savings in areas such as laboratory operations and pre-market assessments.

Interviewees emphasized the urgent need for predictable, timely and updated data and surveys to accurately capture the current context in order to inform the Program's decisions. In particular, the 2015 Canadian Community Health Survey-Nutrition survey and the 2018 Survey of Canadians' Knowledge and Behaviours Related to Food Safety provide essential data baselines for the Program; however, these surveys have not been repeated, meaning the data currently being used for health risk assessments, policy and regulation development does not reflect current market trends nor contemporary dietary habits. Moreover, there is a risk that confidence in the Program's role will diminish over time without adequate surveillance data to underpin its key activities.

The Program has mechanisms in place for performance measurement, including Performance Information Profile indicators (PIP) and operational dashboards. However, the reporting frequency for these indicators varies, and some Program activities are not included in the PIP outcomes. Recent changes have brought the former Food Directorate and the Office of Nutrition Policy and Promotion (ONPP) under one management structure, the Food and Nutrition Directorate, therefore creating an opportunity to improve performance measurement. There is evidence that substantial data is being actively collected; however, improvements are necessary to make the data more relevant for assessing Program achievements and progress towards expected outcomes.

Recommendations

Recommendation 1: Review the Program's partnership with CFIA to improve engagement and clarify roles and responsibilities in the context of new developments in regulations and the food supply, as well as the renewed Memorandum of Understanding and standard operating procedure for health risk assessments.

Assessing opportunities for improving the clarity of roles and working-level relationships between the Program and CFIA, based on progress already made since the last evaluation, could help to address issues like research priority setting, effective use of existing committees, addressing the impacts of regulatory changes on CFIA, and further improving how HRAs are requested by CFIA.

Read Management Response

Recommendation 2: Review the Program's external stakeholder consultation process to improve inclusiveness and transparency.

Although there was positive feedback that stated that many aspects of the Program's stakeholder engagement efforts are effective and inclusive, interviewees pointed out possible improvements aimed at increasing the effectiveness of consultations. Reviewing the Program's full consultation process and mechanisms could yield further improvements in inclusiveness and transparency, resulting in better and more feedback to support decision making.

Read Management Response

Recommendation 3: Prioritize the availability of predictable, timely and updated surveillance data to support Program activities.

Many stakeholders mentioned the importance of having up-to-date data to reflect current trends in food safety and nutrition, in order to support policy development. Despite financial barriers preventing previous surveys from being repeated, consideration should be given to how these gaps could be addressed.

Read Management Response

Recommendation 4: Improve performance indicators and measurement tools to reflect the full scope of Program activities.

Gaps in the Program logic model and performance measurement framework make it challenging to assess the Program's progress towards achieving expected outcomes. Reviewing the Program's performance measurement framework in light of the new merged Food and Nutrition Directorate could yield a more holistic understanding of the Program for internal and external reporting.

Read Management Response

Management Response and Action Plan

Recommendation 1

Review the Program's partnership with CFIA to improve engagement and clarify roles and responsibilities in the context of new developments in regulations and the food supply, as well as the renewed Memorandum of Understanding and standard operating procedure for health risk assessments.

Management response

The Food and Nutrition Directorate agrees with the recommendation that further work is required to improve engagement with CFIA. The HC-CFIA partnership provides the foundation for maintaining the safety of food in Canada and protecting the health of Canadians. However, as Health Canada and CFIA have overlapping, yet distinct mandates and commitments with respect to food safety, this can result in a disconnect in work prioritization and resource allocation.

With regards to the challenges raised related to the perceived lack of engagement and coordination on the Supplemented Foods Regulations, the Program took significant measures to consult CFIA during policy and regulatory development, as well as to support CFIA's compliance and enforcement activities following implementation of the regulations. For example, in addition to regular updates and discussions at senior levels of management, the Program provided CFIA with a walkthrough of the final Regulations; developed detailed guidance, training material, and operational tools to support CFIA inspectors; and established multiple working groups with CFIA counterparts to share information and manage issues on different aspects of the new Regulations.

Nevertheless, management recognizes that there is room for the Program to further improve how it engages CFIA in the context of developing new policies, regulations and other risk management measures. In particular, the Program could take additional steps to assess impacts and resource needs, and set clear processes, roles and responsibilities.

While management agrees with the challenges raised in the evaluation around Health Risk Assessments (HRAs), overall, the process of working with CFIA to develop and agree on procedures set out in the HRA Standard Operating Procedure (SOP) has allowed the two offices to solidify relationships, which has enhanced operations. The SOP has proven useful and has helped with consistency and time saving when training new staff.

As HRAs for SFs, including caffeinated energy drinks, have become more prevalent following the coming into force of the Supplemented Foods Regulations in 2022, the Food and Nutrition Directorate is still gaining experience that could help establish more specific guidelines beyond the safety-based maximum levels and labelling requirements established in the list of permitted supplemental ingredients, e.g., for well-known ingredients such as caffeine. Recently, the Directorate provided guidance to CFIA regarding information required by Health Canada for Supplemented Foods-related HRAs which appear to have resulted in a significant decrease in the number of HRAs requested. Additionally, the Directorate and CFIA have implemented two working groups related to supplemented foods to ensure ongoing communication and collaboration. One of these working groups is a food safety working group, which, in part, will work to develop lessons learned from the 2023-24 caffeinated energy drinks recalls, as well as discuss other ad hoc issues related to the safety of supplemented foods.

Recommendation 2

Review the Program's external stakeholder consultation process to improve inclusiveness and transparency.

Management response

The Food and Nutrition Directorate agrees with the recommendation. Beyond the stakeholder consultation process, the Directorate is taking steps to improve stakeholder management and engagement activities. In spring 2023, the Directorate reviewed stakeholder engagement practices to assess current practices, identify challenges, uncover opportunities for burden reduction, resource efficiency, and innovation. The Directorate follows the Government of Canada's policies and guidance for consultation and engagement, including the Cabinet Directive on Regulation. Through various initiatives and channels, it aims to keep stakeholders informed of Directorate activities and consultations, while providing evidence-based outreach, education, and guidance to the public. The Directorate also strives to foster a more coordinated, predictable and transparent environment for stakeholders, through initiatives such as the Departmental Forward Regulatory Plan, and food labelling coordination efforts with the CFIA. While limited travel impacted some in-person interactions, the Directorate maintained robust connections with stakeholders by actively participating in virtual meetings, conferences, and discussions with health and industry stakeholders, domestic and international partners, and academia. Engagement with partners and experts from industry, academia, and other sectors remains integral to the Directorate's mission to deliver evidence-based information and guidance. However, the Directorate recognizes that there are areas needing improvement, such as outdated and challenging-to-navigate web information, limitations with mailing lists and CSIMS, and some gaps in engagement practices.

Recommendation 3

Prioritize the availability of predictable, timely and updated surveillance data to support Program activities.

Management response

The Food and Nutrition Directorate agrees with the recommendation. Over the years, the Directorate has established relationships with various partners to access the data it needs to support its risk assessment, policy and regulatory development and evaluation, and pre-market assessment activities. However, with increased costs in accessing food and nutrition surveillance information, the limited resources of the Directorate and its partners, and the fast pace of changes observed in the food environment, having access to updated data in a timely manner and at a predictable frequency has been challenging. To address these challenges, the Directorate is looking at finding efficiencies and opportunities within its organization to leverage existing datasets, optimize the collection of information, and disseminate the information to data users in a more efficient way. The Directorate will also leverage its relationship with partners and stakeholders to look for new opportunities to access information, innovative approaches to collect, analyze and disseminate food and nutrition surveillance information, as well as identify opportunities to seek additional financial resources.

Recommendation 4

Improve performance indicators and measurement tools to reflect the full scope of Program activities.

Management response

Management agrees with the recommendation.

The merger of the former Food Directorate and Office of Nutrition Policy and Promotion (ONPP), which took place at the end of the Evaluation period (April 2024), provides an opportunity to assess the full scope of the Food and Nutrition Program's performance management activities, as reflected in the Program Performance Information Profile (PIP), PIP Annexes for targeted initiatives, and operational dashboards, to improve its usability and effectiveness for the new Food and Nutrition Directorate.